Privacy policy

In this privacy policy, we provide information on which personal data we process in connection with our activities and operations, including our www.24crypto.ch-Website. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of the persons whose data we process.

Further data protection declarations and other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation may apply to individual or additional activities and operations.

We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

In its decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. In a report dated January 15, 2024, the European Commission confirmed this adequacy decision.

1. Contact addresses

Responsibility for the processing of personal data:

24crypto GmbH

24crypto GmbH

Hauptstrasse 10

4450 Sissach

Switzerland

support@24crypto.ch

In individual cases, there may be other controllers for the processing of personal data or joint controllership with at least one other controller.

1.1 Data protection officer or data protection consultant

We have the following data protection officer or the following data protection advisor as a point of contact for data subjects and authorities for inquiries relating to data protection:

Jamie Luca Waiz

Hauptstrasse 10

4450 Sissach

support@24crypto.ch

1.2 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR:

VGS Datenschutzpartner GmbH

Am Kaiserkai 69

20457 Hamburg

Germany

info@datenschutzpartner.eu

The Data Protection Representation serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries in connection with the GDPR.

2. Terms and legal basis

2.1 Terms

Personal data is any information relating to an identified or identifiable natural person.

Personal data particularly worthy of protection are data on trade union, political, religious, or ideological views and activities, data on health, privacy or ethnic or racial affiliation, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

A data subject is a natural person about whom we process personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

2.2 Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data in accordance with at least one of the following legal bases:

• Art. 6 para. 1 letter b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.

• Art. 6 para. 1 letter f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.

• Art. 6 para. 1 letter c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).

• Art. 6 para. 1 letter e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.

• Art. 6 para. 1 letter a GDPR for the processing of personal data with the consent of the data subject.

• Art. 6 para. 1 letter d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.

3. Type, scope, and purpose

We process the personal data that is required to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.

We process personal data for the duration required for the respective purpose(s) or by law. Personal data that no longer needs to be processed is anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.

As a matter of principle, we only process personal data with the consent of the data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.

4. Communication

We process personal data in order to be able to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, for example by mail or e-mail. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. Among other things, the accuracy of the personal data transmitted must be ensured.

5. Data security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication - like all digital communication in principle - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. We also cannot rule out the possibility that individual data subjects may be subject to targeted surveillance.

6. Personal data abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.

We may export personal data to all countries and territories on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - in accordance with the decision of the European Commission.

We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.

7. Rights of data subjects

7.1 Data protection claims

We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:

• Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.

• Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.

• Deletion and objection: Data subjects can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.

• Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may defer, restrict, or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

7.2 Legal protection

Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for complaints by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities for complaints from data subjects - if and insofar as the General Data Protection Regulation (GDPR) is applicable - are organized as members of the European Data Protection Board (EDPB). In some Member States in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.

8. Use of the website

8.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies - at least if and to the extent necessary.

For cookies that are used to measure success and reach or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Logging

We may log at least the following information for each access to our website and our other online presence, insofar as this information is transmitted to our digital infrastructure during such accesses: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. The information is required in order to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.

8.3 Tracking pixels

We can integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as log files.

9. Notifications and messages

We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.

9.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

9.2 Consent and objection

You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.

In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.

10. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. In particular, these provisions provide information about the rights of data subjects directly in relation to the respective platform, including, for example, the right to information.

11. Third party services

We use the services of specialized third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.

For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.

11.1 Digital infrastructure

We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

• Amazon Web Services (AWS) including Amazon CloudFront: Storage space, Content Delivery Network (CDN) and other infrastructure; Provider: Amazon Web Services Inc. (USA) for users in Switzerland / Amazon Web Services EMEA SARL (Luxembourg) for users in the European Economic Area (EEA);

Information on data protection: Privacy Policy, “Data Protection Center”, “Frequently Asked Questions about Data Protection”, “General Data Protection Regulation (GDPR) Center”.

• METANET: Hosting; Service provider: METANET AG (Switzerland); Information on data protection: Privacy policy, “Technical and organizational measures”.

11.2 Automation and integration of apps and services

We use specialized platforms to integrate and connect existing third-party apps and services. We can also use such “no-code” platforms to automate processes and activities with third-party apps and services.

11.3 Audio and video conferencing

We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.

11.4 Payments

We use specialized service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions or data protection declarations, also apply to the processing of payments.

We use in particular:

• Datatrans: Processing of payments; Provider: Datatrans AG (Switzerland); Information on data protection: Data protection regulations, “Security & Compliance”.

11.5 Identity verification

We use third-party services to verify the identity of users. We require such services in particular for age verification for content and services that we are only permitted to offer or wish to offer to persons of legal age and for identity verification for offers where “Know Your Customer” (KYC) obligations exist.

We use in particular:

• IDnow: Identity verification platform; Service provider: IDnow GmbH (Germany); Information on data protection: Privacy policy, “Frequently asked questions about data protection”, “Data security”.

12. Measuring success and reach

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the IP addresses of individual users are stored to measure success and reach. In this case, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data minimization through the corresponding pseudonymization.

Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created include, for example, the individual pages visited, or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.

We use in particular:

• Matomo: Success and reach measurement; Provider: InnoCraft Ltd. (New Zealand, free open-source software); Information on data protection: Use on our own digital infrastructure and with pseudonymized IP addresses, “List of all Matomo features”.

13. Final provisions

We have created this data protection declaration with the data protection generator from Data Protection Partner.

We may amend and supplement this privacy policy at any time. We will inform you of such amendments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.